567 F.Supp.3d 901
N.D. Ill.2021Background
- Rochona Majumdar is a long‑time University of Chicago professor and Illinois resident; C. Christine Fair is a Georgetown professor residing in Virginia.
- Fair posted blogs, tweets, and Facebook posts (2017–2021) repeating a 2017 Title IX letter and alleging Majumdar sexually harassed/assaulted a former student (Zain Jamshaid), engaged in nepotism, and preyed on students.
- Fair repeatedly used the "@UChicago" handle and tagged University‑affiliated/Illinois users; she reposted Jamshaid’s GoFundMe and urged University action.
- Majumdar alleges reputational injury in Illinois (panel cancellation, student boycott) and sued Fair in federal court (diversity) for defamation and false light; Fair moved to dismiss for lack of personal jurisdiction under Rule 12(b)(2).
- The district court applied the Calder/Walden framework and denied Fair’s motion, finding Fair purposefully directed her online campaign at Illinois (the University community) and that jurisdiction comported with due process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fair "purposefully directed" tortious conduct at Illinois (express aiming) | Majumdar: Fair targeted the University of Chicago and its community (used @UChicago, tagged Illinois users) and sought to pressure the University, so Fair expressly aimed conduct at Illinois. | Fair: Posts were public internet publications accessible everywhere and not specifically aimed at Illinois; social media mentions/tags are not equivalent to direct contacts. | Court: Held Fair purposefully directed conduct at Illinois; @UChicago mentions and tags are akin to deliberate contacts and the University/community were the "focal point." |
| Whether Majumdar’s claims "arise out of or relate to" Fair’s forum contacts | Majumdar: The injuries (reputational harm) flowed from Fair’s social media campaign targeting the University, so the claim arises from those contacts. | Fair: The posts targeted a broad, international audience; contacts with Illinois are insufficiently specific. | Court: Held the claim arises from forum contacts because Illinois was the focal point of the story and harm; minimum contacts satisfied. |
| Whether exercising jurisdiction comports with fair play and substantial justice | Majumdar: Illinois has a strong interest; it is the convenient forum for witnesses and evidence; other factors favor jurisdiction. | Fair: Defending in Illinois is burdensome and the matter has broad, international interest. | Court: Held defendant did not show a compelling case against jurisdiction; balancing of factors favors Majumdar and jurisdiction is reasonable. |
Key Cases Cited
- Calder v. Jones, 465 U.S. 783 (1984) (forum‑directed reputational injury can establish specific jurisdiction where the forum is the focal point of the story and harm)
- Walden v. Fiore, 571 U.S. 277 (2014) (jurisdictional contacts must be with the forum, not merely with a forum resident)
- Tamburo v. Dworkin, 601 F.3d 693 (7th Cir. 2010) (online statements encouraging forum‑based action can support jurisdiction; emails/web posts to forum residents are relevant contacts)
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts and fair play/substantial justice standard)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (general jurisdiction requires contacts so substantial defendant is "at home" in forum)
- Felland v. Clifton, 682 F.3d 665 (7th Cir. 2012) (standards for purposeful availment/due process and weighing fairness factors)
- uBID, Inc. v. GoDaddy Grp., Inc., 623 F.3d 421 (7th Cir. 2010) (plaintiff’s burden to make prima facie showing of jurisdiction on written submissions)
- Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796 (7th Cir. 2014) (plaintiff cannot be the only link between defendant and forum; defendant’s own contacts matter)
- Vangheluwe v. Got News, LLC, 365 F. Supp. 3d 850 (E.D. Mich. 2019) (doxing‑style online posts that seek forum‑based retribution can establish purposeful direction)
- Gilmore v. Jones, 370 F. Supp. 3d 630 (W.D. Va. 2019) (online publications focused on forum events and citizens supported personal jurisdiction)